The statutory regulation at the federal level embodied in the Emergency Medical Treatment and Active Labor Act (EMTALA) and the Health Insurance Portability and Accountability Act (HIPAA) as it regards electronic medical records, the Core Measures-Quality Check and Accountability Measures of CMS and the TJC accreditation requirements for Medication Reconciliation (MedRec) will be the focus of attention for this chapter.
Emergency Medical Treatment and Labor Act
Few government acronyms can engender visceral reactions in emergency physicians like the incantation of EMTALA (Emergency Medical Treatment and Labor Act). EMTALA was enacted by Congress in 1986 as an “antidumping” law.1,2 EMTALA is explored in greater depth in Chapter 89. However, in this chapter, EMTALA will be briefly introduced to give the necessary context to our discussion of emergency medicine's current regulatory environment.
EMTALA is federal law requiring hospitals with EDs to provide a medical screening exam (MSE) and to treat the emergency medical conditions of patients in a nondiscriminatory manner, regardless of a patient's ability to pay, insurance status, national origin, race, creed, or color. EMTALA also legislates that receiving hospitals able to provide a necessary and higher level of care must do so.
EMTALA's enforcement power lies in the Medicare dollars that participating hospitals receive. Most hospitals rely on Medicare dollars and could not function without them. Few hospitals can afford, therefore, to eschew CMS oversight and Medicare funding.
EMTALA mandates ED's care for every patient who shows up at the doors (or within 250 yards!). Also, receiving hospitals cannot refuse to accept the transfer of a patient that they have the ability to treat at a higher level than the sending hospital. EMTALA arguably protects patients by ensuring that they are seen and transferred to the level of care needed.
EMTALA hangs around the necks of emergency doctors and nurses like a stethoscope: EMTALA is always there, and sometimes even helps with the job of saving lives and limbs. At times, the law, unlike the stethoscope, is a whip to herd other doctors and hospitals. Threats of EMTALA violations exist in the halls of all facilities.
When an individual comes to the ED, the hospital must provide an MSE within the capability of the hospital's ED, including ancillary services routinely available to the ED, to determine whether or not an emergency medical condition (EMC) exists.
The examination must be conducted by an individual(s) who is determined as qualified by hospital bylaws or rules and regulations and who meets the requirements of $482.55 interpretive guidelines for EMTALA.3 This point is imperative to remember. If an organization allows physician assistants (PA) to perform MSEs, the medical director must have previously delegated this responsibility (allowing PAs to perform MSEs) with documented evidence in the hospital bylaws or rules and regulations. The MSE can be as simple as performing a physical assessment for a complaint of an earache. The MSE could be more resource intensive to involve a CT scan or lumbar puncture for the complaint of “the worst headache of my life.” The bottom line is the MSE is not complete until the determination of whether or not an EMC exists.
Once the MSE is finished and the emergency physician has decided that the patient needs to be transferred to a facility that can provide a needed higher standard of care, EMTALA again comes into play. A call is placed to the intended receiving hospital and if an open bed is available and an on-call physician to care for the patient's specific need, the intended receiving hospital, under threat of violating EMTALA.
A patient may request a transfer to another institution, in which case the physician is not obligated to document the risks and benefits of transfer. However, the transfer must still be an “appropriate transfer.”
The regulations also require that if a physician has violated the EMTALA provision requiring that the physician respond if on call and failed to do so, the information conveyed by the transferring hospital to the receiving hospital must include the physician's name and address.5 Again with the whip—the threat of an EMTALA violation! (See Box 22-1.)
Box 22-1 Requirements for an Appropriate EMTALA Transfer |Favorite Table|Download (.pdf)
Box 22-1 Requirements for an Appropriate EMTALA Transfer
An “appropriate transfer” (a transfer before stabilization which is legal under EMTALA) is one in which all of the following occur:
- The patient has been treated at the transferring hospital, and stabilized as far as possible within the limits of its capabilities.
- The patient needs treatment at the receiving facility, and the medical risks of transferring are outweighed by the medical benefits of the transfer.
- The physician has signed a certification that medical benefits reasonably expected outweigh the risks.
- The receiving hospital has been contacted and agrees to accept the transfer, and has the facilities to provide the necessary treatment.
- The patient is accompanied by copies of the medical records from the transferring hospital.
- The transfer is affected with the use of qualified personnel and transportation equipment, as required by the circumstances, including the use of necessary and medically appropriate life support measures during the transfer.4
Receiving and Transferring Hospitals Can Violate EMTALA
Typically, receiving hospitals violate by refusing to accept while transferring hospitals violate by transferring inappropriately.
A receiving hospital that suspects it may have received an improperly transferred individual is responsible to promptly report to CMS or the State Agency within 72 hours of the occurrence. If the recipient hospital fails to report an improper transfer, the receiving hospital itself may have its Medicare provider agreement terminated.6 After a potential violation has been reported, government surveyors investigate. Surveyors look for evidence that the patient had not been transferred in accordance with the statute.7 Evidence may be obtained from the medical record and through interviews with the individual, family members, or staff. Once the surveyors cross the hospital threshold, they legally have access to everything—they can go anywhere and look at anything8 (Box 22-2)
Box 22-2 EMTALA Validation Survey |Favorite Table|Download (.pdf)
Box 22-2 EMTALA Validation Survey
Surveyors can be expected to review
- The ED log
- Medical records of patients received as transfers, checking that the hospital had agreed in advance to accept the transfer, the hospital had received appropriate medical records (all medical records are to be saved for 5 years)
- Transfers were performed by qualified personnel with transport equipment and medically appropriate life support measures
- That the hospital had available space and qualified staff
The penalties assessed for an EMTALA violation can be substantial. Civil money penalties can be imposed for violations of EMTALA. A participating hospital that is found to negligently violate a requirement of EMTALA is subject to a civil money penalty of up to $50,000 ($25,000 for a hospital with less than 100 beds) for each violation of the statute. A physician who is responsible for the examination, treatment, or transfer of a patient and who is found to negligently violate a requirement of EMTALA may be subject to a civil money penalty of up to $50,000 for each violation of the statute. In addition to monetary fines, physicians who are found to violate EMTALA in a “gross and flagrant” or repeated fashion may be excluded from participation in the Medicare and state healthcare programs. Similarly, an on-call physician who fails or refuses to be available to manage a patient within a reasonable period of time may also be subject to civil money penalties and exclusion from Medicare and state healthcare programs.
In addition, an EMTALA violation opens the door to subsequent tort. Any individual who suffers personal harm as a direct result of a hospital's violation of EMTALA may obtain those damages available for personal injury and equitable relief under state law. Also, any medical facility that suffers a financial loss as a direct result of a hospital's violation of EMTALA may be able to obtain compensation for those damages for financial loss and equitable relief under state law.
EMTALA Reporting Protection
There is some protection for reporting a violation under the law. A participating hospital may not penalize or take adverse action against a physician for refusal to authorize the transfer of the individual with an emergency medical condition that has not been stabilized. Hospital employees reporting alleged EMTALA violations are also protected by this regulation.
A recommended best practice to avoid a violation in the ED is to have the ED charge nurse review all transfer papers prior to the patient exiting the department and provide a legible signature on the bottom of the final page for tracking purposes (Box 22-3).
Box 22-3 Best Practice to Avoid EMTALA Violation |Favorite Table|Download (.pdf)
Box 22-3 Best Practice to Avoid EMTALA Violation
Verification includes checking that
- The physician has signed the certification statement that the benefits of the transfer outweigh the risks
- There is an accepting MD and an accepting representative identified on the transfer papers at the receiving center
- Copies of all pertinent medical records are sent with the patient
- Unstable patients are transported by qualified staff with appropriate life-saving equipment and supplies
Establish a policy for the hospital's transfer papers to be in triplicate. One copy is sent with the patient, the original is sent to medical records, and a copy is sent to risk management to monitor for 100% accuracy and thoroughness as a performance improvement project.
Electronic Medical Records and Privacy (HIPAA)
Hospital EDs are required by the government to transition to electronic medical records (EMRs). The government sees this push as a route to increased efficiency and ultimately as a source of downward pressure on health costs. However, the transition is generally fraught with complex changes in operational processes.
One frequent concern involves the potential for a HIPAA violation of patient confidentiality. As an example, there are numerous high-profile stories about celebrities' medical records being accessed by hospital staff without permission.9 More insidious even than breaches in confidentiality are threats of identity theft.
Barriers to successful implementation of EMRs include confusion over noncommunicating software and hardware systems, lack of institutional experience, shortage of adequate funding, and unavailability of knowledgeable staff. In addition, implementation anxiety is driven by threats of visits from the regulatory agencies (Health and Human Services, Office of Civil Rights and the Attorneys General) and subsequent fines.
State privacy laws and federal HIPAA rules mandate the confidentiality of medical information and impose administrative fines for the unauthorized use of medical information. The laws require the providers of healthcare to establish and implement appropriate administrative, technical, and physical safeguards to protect the privacy of a patient's medical information. Providers, including EDs, are expected to reasonably safeguard confidential medical information from any unauthorized access or unlawful access, use, or disclosure (Box 22-4).
Box 22-4 Requirements for HIPAA Compliance |Favorite Table|Download (.pdf)
Box 22-4 Requirements for HIPAA Compliance
To avoid penalties, EDs must create risk minimizing strategies to prevent unauthorized access:
- First, review and decide which information should be protected.
- Determine how the patient's medical information should be protected and who should have access to the data.
- Establish what controls should be in place and where in the system they should occur.
- Finally, audit to ensure compliance. EDs should create policies and procedures to handle sensitive patient medical information and to self-report to DHHS data breaches.
- Clearly this begins with educating staff to ensure compliance and continues with monitoring for outcomes.
- Reasonable safeguards include building in data encryption, as well as user and role-based access.
For example, the California Department of Public Health can assess an administrative fine or civil penalty for any violation of confidentiality by a healthcare facility. Penalties imposed by AB 211 in California vary depending on the circumstances of the violations, but they include $2500 for the first offense, $10,000 for a second offense, and $25,000 for each subsequent offense. If the use is for financial gain, a licensed healthcare provider shall be subject to a penalty of up to $5000 for the first offense, $25,000 for a second offense, and $250,000 for subsequent offenses.
Although practitioners are cautioned to implement the EMR with great care and attention to confidentiality, CMS clearly intends to incentivize providers and organizations to use an EMR. HITECH EMR incentive registration opened on January 3, 2011. Application qualified facilities for $44,000 in additional Medicare funds for meaningful use of electronic health records.10,11
Table 22-1 summarizes 15 core objectives which must be met by an EMR. Table 22-2 provides the menu from which 5 additional objectives must be selected; the standards by which achievement of these objectives will be measured are provided.
Table 22-1 Meaningful Use of Core Objectives |Favorite Table|Download (.pdf)
Table 22-1 Meaningful Use of Core Objectives
1. Record patient demographics (sex, race, ethnicity, date of birth, preferred language, and in the case of hospitals, date and preliminary cause of death in the event of mortality)
More than 50% of patients' demographic data recorded as structured data
2. Record vital signs and chart changes (height, weight, blood pressure, body-mass index, growth charts for children)
More than 50% of patients 2 years of age or older have height, weight, and blood pressure recorded as structured data
3. Maintain up-to-date problem list of current and active diagnoses
More than 80% of patients have at least 1 entry recorded as structured data
4. Maintain active medication list
More than 80% of patients have at least 1 entry recorded as structured data
5. Maintain active medication allergy list
More than 80% of patients have at least 1 entry recorded as structured data
6. Record smoking status for patients 13 years of age or older
More than 50% of patients 13 years of age or older have smoking status recorded as structured data
7. For individual professionals, provide patients with clinical summaries for each office visit; for hospitals, provide an electronic copy of hospital discharge instructions on request
Clinical summaries provided to patients for more than 50% of all office visits within 3 business days; more than 50% of all patients who are discharged from the inpatient department or ED of an eligible hospital or critical access hospital and who request an electronic copy of their discharge instructions are provided with it
8. On request, provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, medication allergies, and for hospitals, discharge summary and procedures)
More than 50% of requesting patients receive electronic copy within 3 business days
9. Generate and transmit permissible prescriptions electronically (does not apply to hospitals)
More than 40% are transmitted electronically using certified EHR technology
10. Provide computer provider order entry (CPOE) for medication orders
More than 30% of patients with at least 1 medication in their medication list have at least 1 medication ordered through CPOE
11. Implement drug—drug and drug-allergy interaction checks
Functionality is enabled for these checks for the entire reporting period
12. Implement capability to electronically exchange key clinical information among providers and patient-authorized entities
Perform at least 1 test of EHRs capacity to electronically exchange information
13. Implement 1 clinical decision support rule and ability to track compliance with the rule
One clinical decision support rule implemented
14. Implement systems to protect privacy and security of patient data in the EHR
Conduct or review a security risk analysis, implement security updates as necessary, and correct identified security deficiencies
15. Report clinical quality measures to CMS or states
For 2011, provide aggregate numerator and denominator through attestation; for 2012, electronically submit measures
Table 22-2 Menu Set: Requirement for Eligible Providers |Favorite Table|Download (.pdf)
Table 22-2 Menu Set: Requirement for Eligible Providers
Menu Set (implement 5 out of 10)
1. Implement drug formulary checks
Drug formulary check system is implemented and has access to at least 1 internal or external drug formulary for the entire reporting period
2. Incorporate clinical laboratory test results into EHRs as structured data
More than 40% of clinical laboratory test results that are in positive/negative or numerical format are incorporated into EHRs as structured data
3. Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, or outreach
Generate at least 1 listing of patients with a specific condition
4. Use EHR technology to identify patient-specific education resources and provide those to the patient as appropriate
More than 10% of patients are provided patient-specific education resources
5. Perform medication reconciliation between care settings
Medication reconciliation is performed for more than 50% of transitions of care
6. Provide summary of care record for patients referred or transitioned to another provider or setting
Summary of care record is provided for more than 50% of patient transitions or referrals
7. Submit electronic immunization data to immunization registries or immunization information systems
Perform at least 1 test of data submission and follow-up submission (where registries can accept electronic submissions)
8. Submit electronic syndromic surveillance data to public health agencies
Perform at least 1 test of data submission and follow-up submission (where public health agencies can accept electronic data)
Additional Choices for Hospitals and Critical Access Hospitals
9. Record advance directives for patients 65 years of age or older
More than 50% of patients 65 years of age or older have an indication of an advance directive status recorded
10. Submit electronic data on reportable laboratory results to public health agencies
Perform at least 1 test of data submission and follow-up submission (where public health agencies can accept electronic data)
Core and Accountability Measures
Acute care hospitals receive reimbursement for Medicare patients only if they are accredited by The Joint Commission (TJC) or equivalent accrediting body. TJC established the reporting of quality measures nationally for accredited hospitals in 1998 with the implementation of the ORYX initiative. The goal of the initiative was to ensure a continuous, comprehensive, data-driven accreditation method that focuses on outcomes/actual results, rather than the processes of care. The ORYX initiative requires hospitals to identify and begin to use existing quality measurement systems and to produce quality measurement results as a part of TJC accreditation process.12
The Joint Commission Accountability Measures
Organizations had over 100 quality indicators from which to choose that aligned with the hospitals' goals while adhering to TJC ORYX requirements. This system TJC initiative was not without issues; the lack of requirements for standardized measurements led to the inability for comparison among the sites.
In 2002, accredited hospitals were required to collect and report data on 2 of the 4 established core measures (acute myocardial infarction, heart failure, pneumonia, and pregnancy). These data were made public by TJC in 2004.13 Core measures are a set of standardized, or “core,” evidence-based performance measures used to treat an identified illness that were introduced by TJC and later adopted by CMS.14 The intent of the measures is to improve the quality of healthcare delivered in the hospital. A hospital's performance is measured by its adherence to the core measure guidelines. Each diagnosis has a set of evidence-based treatments, tests, and standards to follow. Use of order sets by the practitioners guarantees that evidence-based medicine was delivered. Nursing must follow all orders as prescribed 100% of the time. Core measure adherence indicates the patients are receiving high-quality safe patient care. Some standardized core measure sets are listed in Box 22-5.
Box 22-5 CMS Current Hospital Quality Measures |Favorite Table|Download (.pdf)
Box 22-5 CMS Current Hospital Quality Measures
Standardized core measure sets14
- Acute myocardial infarction
- Heart failure
- Surgical care improvement project
- Perinatal care
- Children's asthma care
- Hospital outpatient
- Hospital-based inpatient psychiatric services
- Venous thromboembolism
The performance data are directly reported by the hospital to the regulatory agencies and the results are made public on www.qualitycheck.org and updated quarterly.
In effect as of January 2012, there are 2 core measures for inpatient discharges that originate in the ED. The first is ED throughput for admitted patients. This measure is defined as the median time for ED arrival to ED departure to the inpatient unit and excludes patients not admitted from the ED, placed in observation, or those who have mental disorders. Therefore, an ED must, if it does not already, document in the ED record the date and time when the patient physically left the ED. Emphasis is placed on capturing the latest time the patient was receiving care in the ED, under ED services or awaiting transport.
The second 2012 core measure for EDs is admission decision time to ED departure for admitted patients. Similarly, this measure excludes patients not admitted from the ED, patients placed in observation or those who have mental disorders. To comply, document in the ED record the time and date the decision was made to admit the patient to the hospital as an inpatient. And again, document in the ED record the date and time when the patient physically left the ED.
In order for hospitals to remain accredited, they must report core measures to TJC quarterly. Neglecting to submit data can lead to a requirement for improvement (RFI). Falsification of the reports can trigger a preliminary denial of accreditation. When RFIs are not resolved, facilities can lose their accreditation.
Healthcare consumers can access TJC website and evaluate the performance of hospitals in regard to meeting national requirements within 250 miles of their location. TJC provides hospital-specific information about clinical performance in the care of patients regarding: acute myocardial infarction, heart failure, pneumonia, pregnancy and related conditions (retired effective with April 01, 2010 discharges and replaced by perinatal care), surgical care, and children's asthma care. In addition, Quality Check™ also includes HCAHPs data and the CMS 30-day mortality measures.15
Consumers can access Quality Check at http://www.qualitycheck.org and search for healthcare organizations by name, type, and/or location. Interactive links to information are designed to help individuals better understand how to use and interpret the information presented.
CMS Accountability Measures
In 2004, the CMS began financially penalizing hospitals that did not report to it the same performance data they collected for TJC, and in 2005, the CMS began its own public reporting.13 Nationally, hospitals have taken the performance measures and quality reporting programs of the regulatory agencies seriously and have demonstrated significant improvement in outcomes. In 2009 (data available to the public in September 2010), 96.8% of hospitals showed performance levels greater than 90% for the administration of beta-blockers at discharge to patients who had an acute myocardial infarction (as compared with 49.1% in 2002).13 While some evidence-based core measures can have a positive effect on patient outcomes, others have been found to be less effective. Researchers recently found no positive relationship between hospital performance on the discharge-instruction measure for heart failure and readmission rates.13
As TJC and CMS continue on their journey to maximize health benefits to patients, accountability measures have been established to determine measures that are effective and those that are not. Effective accountability measures are quality measures that meet the 4 criteria that produce the greatest positive impact on patient outcomes when hospitals demonstrate improvement on them.
The criteria are based on The Joint Commission's experience implementing and evaluating the outcomes of quality measures for more than a decade. The criteria are intended to provide a more rational approach to the process of collecting and reporting quality data and they are listed in Box 22-6.13
Box 22-6 Accountability Measures |Favorite Table|Download (.pdf)
Box 22-6 Accountability Measures
Four criteria for accountability measures that address processes of care:
There is a strong evidence base showing that the care process leads to improved outcomes.
The measure accurately captures whether the evidence-based care process has, in fact, been provided.
The measure addresses a process that has few intervening care processes that must occur before the improved outcome is realized.
Implementing the measure has little or no chance of inducing unintended adverse consequences.
In the practice of emergency medicine, there is an awareness of the potentially vast number of chemical compounds, elements, and organic extracts that patients ingest. ED practitioners see prescribed and over-the-counter pharmaceuticals and herbal products and homeopathic tinctures, mass produced nutraceuticals, and culturally distinct home remedies. ED staff examine actual pill bottles with prescription medicines and dosages when brought in by patients. Patients may not even fully divulge some of the substances they take. Further, noncompliance with prescribed medications may not be disclosed. In an attempt to provide order to this wide assortment of ingested chemicals, the regulatory agencies have mandated that hospitals perform Medicine Reconciliation (MedRec).
Reconciling the medications and supplements that an ED patient is taking is only part of the process. Updating a compendium of medicines that should not be taken together, those with adverse reactions and true allergies is a second goal. Additionally, reconciling the list of medications and chemicals on arrival to the ED with the list on disposition (discharge, admission, or transfer) is the third goal of the Medicine Reconciliation process.
TJC continually publish the National Patient Safety Goals (NPSG). In 2012, these safety goals required EDs to “maintain and communicate accurate patient medication information.” Clinicians are told to
“Obtain information on the medications the patient is currently taking when he or she is admitted to the hospital or is seen in an outpatient setting.”
Specifically, the list of medications should describe all current medications, including the scheduled times. The guidelines provide a glossary to define medication:
“Any prescription medication, sample medications, herbal remedies, vitamins, nutraceuticals, vaccines, or over-the-counter drugs; diagnostic and contrast agents used on or administered to persons to diagnose, treat, or prevent disease or other abnormal conditions; radioactive medications, respiratory therapy medications, parenteral nutrition, blood derivatives, and intravenous solutions (plain with electrolytes and/or drugs); and any product designated by the Food and Drug Administration (FDA) as a drug.”
This definition of medication does not include enteral nutrition solutions (which are considered food products), oxygen, and other medical gases.16
TJC acknowledges that it is often difficult to obtain complete information on current medications. The standard states
“It is often difficult to obtain complete information on current medications from a patient. A good faith effort to obtain information from the patient and/or other sources will be considered as meeting the intent… .”
Obtaining this information may include questioning anyone accompanying the patient and ensuring documentation.17
All organizations should develop a Medication Reconciliation Policy. Each department or hospital can define what format will be used to document the patient's current medications. The policy statement should include that all efforts to obtain complete information on current medications from a patient and/or other sources should be documented.
For the sake of regulation, the ED is considered a non-24-hour setting similar to primary care, outpatient radiology, ambulatory surgery, and diagnostic settings. Suggested data points are the name, dose, route, frequency, and purpose of the medication. An ED may choose others as well, but these are suggested as a minimum.
The information on a MedRec should not just be gathered, but also used to compare the medication information the patient brought to the hospital and the history of prescribed medications (records) with the medications ordered for the patient in the ED. Practitioners should review this information with an eye toward identifying and resolving discrepancies.
There is no special language in the regulations that mandates a consideration of medicine interactions. But discrepancy is meant to include “omissions, duplications, contradictions, unclear information, and changes.” A qualified individual, identified by the hospital, does the comparison. Who that individual is in practice and what level of expertise qualifies them is not stipulated. (See also HR.01.02.01 and HR.01.02.05.) However, the leaders of ACEP and ENA sent an address to Mark R. Chassin, MD, MPP, MPH, President of TJC, May 10, 2010:
“We acknowledge that nurses and others can collect information about the patient's medications at the beginning of the patient's encounters. However, only a provider with prescriptive authority can truly reconcile the medication list, ie, identify at the time of discharge what medications the patient should take.”18
Angela F. Gardner, MD, FACEP, President, ACEP, 2010, and Diane Gurney, RN, MSN, CEN, President, ENA, 2010.
MedRec is not just for the provider's information. The process must also provide the patient (or family) with written information on the medications the patient should be taking when being discharged. If the only medications the patient will receive are for a short time period, then the list may only include those medications. (For more information about communications to other providers of care when the patient is discharged or transferred, refer to Standard PC.04.02.01.)
At discharge clinicians are also expected to explain the importance of managing medication information. This communication helps to shift the ongoing burden of responsibility to the patient. The regulations charge the patient with the responsibility of providing a list to their primary care physician and updating the information when medications are discontinued, doses are changed, or new medications (including over-the-counter products) are added. TJC also expects the patient to maintain their medication information. In other words, patients are expected to carry medication information at all times, in case of emergency. (For information on patient education on medications, refer to Standards MM.06.01.03, PC.02.03.01, and PC.04.01.05.)
TJC, during a site survey, may come to the ED and request to see the medication reconciliation policy and procedure. TJC surveyors may even observe staff performing the MedRec process to ensure adherence to the written policy and procedure. To assess compliance, the surveyor may ask the nursing leader to provide 10 open and 10 closed medical records for review.
The CMS requires TJC (or equivalent organization) accreditation by US hospitals since 1965 as a “Condition of Participation” requirement in order to receive Medicaid and Medicare reimbursements (Box 22-7). Without the funding, most hospitals will be forced to close their doors.
Box 22-7 Requirements of the Joint Commission Medication Reconciliation NPSG |Favorite Table|Download (.pdf)
Box 22-7 Requirements of the Joint Commission Medication Reconciliation NPSG
Checklist to ensure ED compliance:
- Develop a medication reconciliation policy
- Define what format will be used to document the patient's current medications
- Document all efforts to obtain complete information on current medications from a patient and/or other sources
- Information collected includes name, dose, route, frequency, and purpose
- The ED provider, a qualified individual identified by the hospital in the rules and regulations, does the comparison of the medication information the patient provides against the medications ordered for the patient to ensure no discrepancies, omissions, duplications, contradictions, or unclear information